municipal stormwater illicit discharge programs, stormwater system maintenance and management, and...
DESCRIPTION
Presentation from a webinar by Ryan Janoch (Mapistry), Wendy Manley (Wendel Rosen Black & Dean LLP) and Jamie Cint (GaiaTech) that focused on municipal stormwater, from program management to permit compliance. Technical considerations, including identifying, reducing and eliminating illicit discharges, and developing and conducting effective asset management (mapping) and maintenance programs are covered. In addition, recent regulatory developments involving municipal stormwater programs are included.TRANSCRIPT
Municipal Stormwater
Illicit Discharge Programs, Stormwater
System Maintenance and Management,
and Recent Regulatory Developments
September 25, 2014
Panel
Ryan Janoch, PE
Mapistry
Wendy Manley, Esq.
Wendell Rosen Black & Dean LLP
Jamie Cint
GaiaTech
Overview
● Asset Management
● Maintenance Program
● Treatment Considerations
● Illicit Discharges
● Education and Outreach Programs
● Paradigm Shift of Stormwater Management
● Regulatory Controls
● Cost & Funding Challenges
Asset Management and
Maintenance
Ryan Janoch, PE
NPDES MS4 Permits
Phase II
1999
small cities
Phase I
1990
cities pop.100,000+
Stormwater Management Plans
(SWMP)
● Both Phase I and II
● Annual report
● Monitor discharges/streams
● Use Best Management Practices (BMPs)
Asset Management
● Permit required
● Field data collection - maintenance crews,
staff, consultants, and citizens
● New records and update existing records
● Consistency in naming conventions
● Training field teams
Field Data Collection
● What is the necessary info?
● Who does the collection?
● How to collect it?
● Where is it stored?
● What do we do with it?
Stormwater System Mapping
Benefits of Good Asset Programs
● Targeted maintenance
● Plan for repairs and upgrades
● Better models (e.g. planning, expansion,
upgrades)
● Reduce long-term maintenance costs
● Permit compliance
Example: SF Bay Region Phase I
MS4
1. Develop and publicize a stormwater system map
2. Conduct surveys on at least one waterbody each year
3. Submit an annual Urban Creeks Monitoring Report with
maps of sampling locations and data for a waterbody
4. Submit an annual Pilot Green Streets Program Report
showing drainage areas treated by Low Impact
Development (LID) controls
Example: SF Bay Small MS4 (Phase II)
Map Requirements
1.Outfall locations (coordinates and ID)
2.Receiving waterbody locations
3.Priority areas (e.g industrial/commercial)
4.Field sampling locations
5.Permit boundary
Maintenance Programs
● Start with system maps (planning)
● Routine - set schedule and stick to it
● Non-routine - as-needed based on
complaints and inspections
● Update records on site (photos, notes)
● Documentation (records)
Treatment Considerations
● Long-Term Maintenance Costs
● Constituents of Concern (metals, TSS, trash)
● Flow reduction
● Size constraints
● Capital Costs
● Aesthetics
Treatment Options
• Bioretention
• Underground Storage
• Infiltration
• Hydrodynamic Separators
• Media Filtration
• Retention Ponds
• Swales
Compliance and Benefits of
Education: Stormwater
Ponds and Illicit Discharges
Jamie Cint
My Experience as an Inspector
• 24 years of inspecting
• Education/certifications not required to
inspect industrial facilities
• Inspectors and regulators not trained on how
to educate the community
Inspector Experience #1
Most people do not know what the following
are:
● stormwater
● illicit discharge
● best management practice (BMP)
● National Pollution Discharge Elimination
System (NPDES) Municipal Separate
Storm Sewer System (MS4) permit
Inspector Experience #2
Some that believe that the stormwater system
(e.g. curb inlets, infrastructure, drainage
ditches) drains to the sanitary sewer system
and stormwater is treated
Inspector Experience #3
Many look at what they are doing to the
environment (e.g. wash water, cigarettes,
drinks, trash, pesticides) as minor. (It can’t be
that bad, its only a….)
Education is a BMP
Stormwater education programs are to inform
citizens, commercial, and industrial facilities
about:
● their permit requirements
● importance of stormwater pollution
prevention
● environmental impact of stormwater runoff
● methods to reduce environmental impact
Illicit Discharge Education
Illicit (illegal) discharges Examples: motor oil, grass clippings, sediment, pet
waste, pool water
Stormwater Discharges
“Nothing goes in the drain but rain!!”
Certain “Allowable”
Non-Stormwater Discharges
Allowable Non-Stormwater Discharges
● Uncontaminated groundwater
● Foundation drains
● AC condensate (no added chemicals)
● Uncontaminated potable water
● Waterline and fire hydrant flushing
● Irrigation water or lawn watering runoff
● Exterior building wash water (no detergents)
Old A/C
condensate line
The Good….
the Bad…
and the Ugly!!
What do we find at Industrial Facilities?
Best Management Practices
Employee Training
Spill Prevention and Response
Good Housekeeping
Preventative Maintenance Program
On-site Contractor Responsibilities
Exposure Minimization
Daily Visual Observations
Scrap Material Storage and Salvage
Management of Runoff
One on One Training
• During baseline visit
• Walk the entire site - every corner
• Boldly go where no person has gone before!
• Point out the good, the bad, and the ugly
• Daily, quarterly, and annual visits get easier
Cooking Grease Waste Processing
• Daily odor violations and complaints about the staining
• Contaminating the stream (200 feet from the building)
• Department going there for ten years with little results
• I was requested by another department in the county
• By the first hour, the owner asked if I had to be there ☺
The Bad and the Ugly
The Good and the Kick Butt
Commercial and Residential
● Education is more difficult
● They don’t want to hear what they can and
cannot do at their facility or at home
● Education material and information does help
● Many do not know what is hazardous waste
Brochures and Information Packets
What is a hazardous substance?
Biodegradable and No. 1 in Litter
What does biodegradable mean?
Capable of being broken down by
microorganisms
Per the USEPA, for 1 ounce of
biodegradable soap to be safe for fish
it has to be diluted by almost 20,000
ounces of water (156.25 gallons)
Per the USEPA, what
is the most number
one littered item in
America?
Cigarette butts
Storm Water Ponds Commercial,
Residential, and Landscapers
• Commercial and residential areas have detention or
retention ponds
• Most HOAs and commercial owners have no idea what
the purpose of a stormwater pond is or how to maintain it
properly
• How to educate instead of giving violations?
◦ College extension office
◦ HOA meetings
◦ Maintenance companies
Retention & Detention Ponds
Retention Ponds (wet)
Retain water and have a permanent pool of water
Detention Ponds (dry)
Detain water 24-48 hours after a rain event then are dry again.
Landscaper Enforcement
Leaves Blown into the Creek
Leaves in the
Manhole
With Education Comes Great
Responsibility and Commitment
Education takes a lot of time
and effort
Training
Preparation
Streamline your program
Offer classes to industry
Target violators such as
landscaping companies, pool
installers, HOA,
contractors…
Benefits of Education
• Less violations
• More cooperation
• Promote financial growth (e.g. landscapers, clean up
companies)
• Less contaminated stormwater (e.g. lakes, stream,
rivers, oceans)
• More recreation in the community (e.g. boating,
swimming)
• Regulators have a better relationship with the
community
• It’s fun!
The Paradigm Shift of
Municipal Stormwater
Management
Wendy Manley, Esq.
Hydromodification
Evapotranspiration
Runoff
Infiltration
Traditional storm drain design driver
Paradigm Shift:
From Gray Infrastructure …
Designed to quickly drain water away from
development to prevent flooding.
Paradigm Shift: … to Green
Infrastructure
• Designed to mimic natural processes:
• Reduce runoff rates and volumes that scour streambeds
• Reduce discharge of pollutants to receiving waters
LID & Green Infrastructure
• Low Impact Development uses site design and storm water management to maintain the site’s pre-development runoff rates and volumes.
• Green Infrastructure carries this approach to a larger, community scale and presents similar, sustainable opportunities to local governments and regional projects.
SWRCB, Storm Water Management Fact Sheet
Drivers of Change
• Storm Water Permits
– Requirements
– Monitoring
– Numeric Standards
• Drought
– Strained water supplies
– Water efficient landscaping
• CA Green Building Code
• Carbon emission reductions
Paradigm Shift: Stormwater: From
Waste to Resource
• Water Supply
– Capture and reuse
– Groundwater recharge
• Energy savings
• Parks and open space
• Multi-benefit projects
Regulatory Framework
Clean Water Act
Municipal SW Permit
Industrial SW Permit
Municipality Industrial sites
Construction SW Permit
Construction sites
Development & Redevelopment
Regulatory Controls &
Incentives Examples
• LID required where feasible
• LID required for first 0.5 inches of precipitation
• LID required on development/redevelopment
projects that create/replace > 5,000 sq feet
impervious surface
• TMDLs, Numeric Effluent Limits,
• Discounts on SW fees for LID features
• Benchmark exceedances allowed where reduced
flows lower mass loads to below the mass load at
benchmark
Regulatory Controls
Specific Examples (CA Municipal General Permit)
• Concentrate development on portions of the site
w/ less permeable soils, preserve areas that can
promote infiltration
• Replicate the site’s natural drainage patterns
• Detain & retain runoff
throughout the site
• Limit impervious surfaces
• Preserve significant trees
Paradigm Shift:Climate Change
• Change over time, & change in the rate of change
• Increasing variability
• Mentally adjusting to dynamic systems from static (sort of) systems
• Sizing projects – shifting targets
• Design storms – using running averages
Municipal Implementation
Challenges • Retrofitting existing infrastructure – systematic or piecemeal
• On-site features vs. Regional facilities; Watershed planning
• Groundwater protection; Water quality standards
• Standardized requirements vs. site-specific approaches
• Capture and reuse may conflict with water rights
• Establishing legally enforceable programs and standards
– Ordinances
– Contracts
– Leases
– Construction specifications
• Long term maintenance
• Lack of technical knowledge
Costs & Funding Challenges
• Project Costs – May be less using LID
– Economic benefit - greater market value for green space &
“sustainable” development
• Municipal Implementation costs – Regulatory (ordinances, permit approvals)
– Administrative (collecting fees, tracking, inspections)
– Operation & Maintenance
• Municipal Funding – Stormwater utilities
– Service fees
– Legislative funding
Questions?
Ryan Janoch, PE
Wendy Manley, Esq.
Jamie Cint